The inspectors identified a Green non-cited violation (
NCV) of
10 CFR 50.65, Maintenance Rule, paragraph (a)(4), when Ginna did not adequately manage an increase in risk when initiating the
RPS channel 2 calibration procedure, which resulted in an underestimation of the risk and several required risk management tools were not implemented by Ginna operations staff as required. Ginna developed several corrective actions including enhanced procedural guidance for operators and entered the finding into the corrective action program (CR-2011-7071). This finding is more than minor because the overall elevated plant risk would put the plant into a higher licensee-established risk category and required additional risk management actions per plant procedures. This finding is associated with the human performance attribute of the
Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined this finding is of very low safety significance because the
incremental core damage probability deficit was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, work control, in that Ginna did not plan and coordinate work activities consistent with nuclear safety. Specifically, Ginna management was not fully apprised of plant conditions prior to making the actual risk change and before continuing with channel 2 calibration work
